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| The Tax Publishers2021 TaxPub(DT) 0530 (Bang-Trib) INCOME TAX ACT, 1961
Section 92C
Infosys Ltd. was a giant risk taking company and engaged in development and sale of software products and also owned intangible assets and was, therefore, not comparable with a software development service provider such as assessee.
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Transfer pricing - Determination of ALP - Selection of comparables - Huge scale of operations, intangibles and functional dissimilarity
Assessee rendered software development services to its AE abroad. TPO considered Infosys Ltd. as comparable to assessee's case. Held: Infosys Ltd. was a giant risk taking company and engaged in development and sale of software products and also owned intangible assets and was, therefore, not comparable with a software development service provider such as assessee.
Followed:CGI Information Systems & Management Consultants Private Ltd. v. Asstt. CIT IT(TP) A No. 183/Bang/2017 for assessment year 2012-13 Order, dated 11-4-2018.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2012-13
INCOME TAX ACT, 1961
Section 92C
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